"Action Items for Plan Sponsors: [1] Ensure that the plan has processes in place to (i) identify participants who may be high earners subject to the Roth catch-up requirement and (ii) track FICA wages. [2] If the plan allows for Roth contributions, ensure that the plan has a system to implement deemed Roth catch-up elections for participants who are subject to the Roth catch-up requirement. [3] If the plan does not provide for Roth contributions, ensure that the plan does not allow participants subject to the Roth catch-up requirement to make catch-up contributions, or consider amending the plan to allow for Roth contributions."  MORE >>